The
parties in this action agree (Filing No. 29), and it is
hereby ordered, this Protective Order shall govern the use
and dissemination of all information, documents, or materials
produced by the parties and designated as Confidential.

1.
DEFINITIONS.

Limitations
under this Protective Order on the use or disclosure of
documents, deposition testimony or other discovery designated
as "Confidential" shall apply to (a) all
information, copies, extracts and complete or partial
summaries prepared or derived from such documents or
testimony; (b) portions of deposition transcripts, answers to
interrogatories, responses to requests for admissions,
responses to requests for production, initial disclosures and
exhibits thereto which directly refer or directly relate to
any such information, documents, copies, extracts or
summaries; and (c) portions of briefs, memoranda or any other
writing filed with the Court and exhibits thereto which
directly relate to any such information, documents, copies,
extracts or summaries.

2.
CONFIDENTIAL DOCUMENTS.

Before
produced documents are copied or inspected, in order to limit
disclosure as set forth in this Paragraph 2, the producing
party may stamp as "Confidential" any document or
deposition testimony it believes contains confidential or
proprietary business information, health information, and/or
personal or sensitive information contained with police
records. Documents may also be designated as
"Confidential" by written notice to opposing
counsel which identifies the documents so designated by Bates
number. The failure to designate information in accordance
with this Protective Order shall not preclude subsequent
designation of such information as Confidential. Documents
designated "Confidential, " deposition testimony so
designated, and information derived therefrom will be
retained by counsel and will not be used for any purpose
other than this litigation and will not be disclosed except
pursuant to court order entered after notice, to anyone
except:

a. Counsel who have signed this Order approving it as to form
and content; attorneys who are employed or are members of the
law firms of counsel who have signed this Order; in house
counsel; chief officer executive or vice president level
employees of the named parties; law clerks, secretaries or
paralegals directly involved in the conduct of this
litigation;

b. Experts and consultants retained by either of the parties
or their counsel for purposes of assisting in the preparation
or presentation of claims or defenses;

c. Any deposition or trial witness, during the course of
deposition or trial testimony or in preparation for such
testimony, when necessary to the testimony or preparation of
such witness;

d. Any person who was involved in the preparation of the
document;

e. The Court, Court personnel, court reporters and similar
personnel;

f. The named parties to this case, excluding their agents
and/or representatives except those identified at Paragraph
2(a) above.

g. Employees of outside copy services used to make copies of
the Confidential documents.

h. Any other person with the prior written consent of the
party producing the document, pleading or ...

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